Hazard Communication
29 CFR 1910.1200
Objectives
29 CFR 1910.1200
 We will cover:
 Purpose of hazard communication in the workplace
 Role management and employees play in complying
with this standard
 General requirements regarding chemical hazards
 Requirements for an effective written hazard
communication program
Organization of the Final Rule
(a) Purpose
(b) Scope and Application
(c) Definitions
(d) Hazard Classification
(e) Written Hazard Communication Program
(f) Labels and Other Forms of Warning
(g) Safety Data Sheets
(h) Employee Information and Training
(i) Trade Secrets
(j) Effective Dates
Appendixes
 Appendix A, Health Hazard Criteria (Mandatory) – NEW
 Appendix B, Physical Criteria (Mandatory) – NEW
 Appendix C, Allocation of Label Elements
(Mandatory) – NEW
 Appendix D, Safety Data Sheets (Mandatory) – NEW
 Appendix E, Definition of “Trade Secret” (Mandatory)
 Appendix F, Guidance for Hazard Classifications
Re: Carcinogenicity (Non-Mandatory) – NEW
Purpose
1910.1200(a)
 Ensure hazards of all chemicals produced or
imported are classified and that information
concerning the classified hazards is
transmitted to employers and employees
Scope and Application
1910.1200(b)(1)
 Requires chemical manufacturers or importers
to classify the hazards of chemicals that they
produce or import
 Requires distributors to transmit the required
information to employers
Scope and Application
1910.1200(b)(1)
 Requires employers to provide information to
their employees about the hazardous
chemicals to which they are exposed by the
following means:
 Hazard communication (HazCom) program
 Labels and other forms of warning
 Safety data sheets (SDS)
 Information and training
Scope and Application
1910.1200(b)(2)
 Applies to chemicals
known to be present in
the workplace
 Employees that may
have a potential for
exposure
 Under normal conditions
 Foreseeable emergency
Nova Development
or
Scope and Application
1910.1200(b)(3)
 Application for laboratories only
 Labels are not to be removed or defaced
 Maintain SDS for each chemical
 SDS must be readily available
 Provide information and training
» Except location and availability of HazCom program
 A laboratory that ships chemicals is considered to be a
distributor or manufacturer:
 Must ensure that containers are appropriately labeled prior to
shipment, and
 SDS is provided to other distributor(s) or employer(s)
Scope and Application
1910.1200(b)(4)
 Application for work operations where
chemicals are handled only in sealed
containers
 Labels not to be removed or defaced
 Maintain SDS for each chemical
 SDS must be readily accessible
 Provide information and training
» Except location and availability of HazCom program
» Trained to protect themselves in the event of a spill or leak
Scope and Application
1910.1200(b)(5)
 Exemptions for labeling
 Pesticides beverage
 Chemical substance or mixture
 Food, food additive, color additive, cosmetic,
medical or veterinary device or product
 Distilled spirits, wine or malt beverage
 Consumer product or hazardous substance
 Agricultural or vegetable seed treated with
pesticides
Scope and Application
 Standard does not apply to:
 Hazardous wastes and substances
 Tobacco or tobacco products
 Wood or wood products
 Articles as defined in the standard
 Food or alcoholic beverages
 Drugs
1910.1200(b)(6)
Scope and Application
 Standard does not apply to:
 Cosmetics for retail sale
 Consumer products
 Nuisance particulates
 Ionizing and nonionizing radiation
 Biological hazards
1910.1200(b)(6)
Key Elements of HazCom
 Hazard classification
 Written program
 Labeling
 SDS
 Employee training
1910.1200
Definitions
1910.1200(c)
 “Chemical”
 Any substance or mixture of substances
 “Substance”
 Chemical elements and their compounds in the
natural state or obtained by any production
process
Definitions
 “Hazardous chemical”
 Any chemical that is classified as a
» Physical hazard
» Health hazard
» Simple asphyxiant
» Combustible dust
» Pyrophoric gas
» Hazard not otherwise classified
1910.1200(c)
Definitions
1910.1200(c)
 “Physical hazard”
 A chemical classified as posing one of the following
hazardous effects:
»
»
»
»
»
»
»
»
»
»
Explosive
Oxidizer (liquid, solid or gas)
Self-reactive
Pyrophoric (liquid or solid)
Self-heating
Organic peroxide
What’s the hazard?
Corrosive to metal
Gas under pressure
Emits flammable gas in contact with water
Flammable (gases, aerosols, liquids or solids)
Definitions
1910.1200(c)
 “Health hazard”
− A chemical that is classified as posing one of the
following hazardous effects:
»
»
»
»
»
»
»
»
Acute toxicity (any route of exposure)
Skin corrosion or irritation
Serious eye damage or eye irritation
Respiratory or skin sensitization
Germ cell mutagenicity
Carcinogenicity
Reproductive toxicity
Specific target organ toxicity
(single or repeated exposure)
» Aspiration hazard
Definitions
1910.1200(c)
 “Pyrophoric gas”
 A chemical in a gaseous state that will ignite
spontaneously in air at a temperature of 130
degrees F (54.4 degrees C) or below
Definitions
1910.1200(c)
 “Simple asphyxiant”
 A substance or mixture that displaces oxygen in the
ambient atmosphere and can cause oxygen
deprivation in those who are exposed, leading to
unconsciousness and death
Definitions
1910.1200(c)
 “Hazard not otherwise classified (HNOC)”
 An adverse physical or health effect identified
through evaluation of scientific evidence during the
classification process that does not meet the
specified criteria for the physical and health hazard
classes addressed in this section (standard)
 The effect either:
» Falls below the cut-off value/concentration limit of this
hazard class, or
» Is under a GHS hazard category not adopted by OSHA
(e.g., acute toxicity Category 5)
Hazard Classification
1910.1200(d)
 Each type of hazard covered is considered a “hazard
class”
 Examples: acute toxicity, carcinogenicity
 Most hazard classes are also subdivided into “hazard
categories” to reflect the degree of severity of the effect
 This is the concept of “classification”—rather than just
determining that there is a hazardous effect (e.g.,
carcinogenicity), there is also a finding of how severe
that effect might be (e.g., category 1 or 2)
Hazard Classification
1910.1200(d)
 Those that evaluate chemicals must follow
procedures in Appendixes “A” and “B”
 When classifying mixtures, manufacturers/
importers may rely on SDS for individual
ingredients unless SDS known to omit or
misstate required information
 Employers are not required to classify
chemicals
Appendix A - Health Hazard Criteria
 OSHA adopted all of the health hazard classes
in the GHS—the criteria to define each of these
are found in Appendix A—Health Hazard
Criteria (Mandatory)
 However, the agency did not adopt the following
hazard categories:
 Acute toxicity: Category 5
 Skin corrosion/irritation: Category 3
 Aspiration hazard: Category 2
Mixtures
Appendix A.0.4-0.5
 Uses a tiered approach to mixtures, with each
health hazard class having a specific approach
 Step 1: Use available test data on the mixture as a whole to
classify the mixture based on the substance criteria
 Step 2: Use bridging principles to extrapolate from other data
(e.g., dilution principle)
 Step 3: Estimate hazards based on known information
regarding the ingredients of the mixture (cut-offs may be applied)
 Chemical manufacturers and importers may rely on
the information provided in ingredient SDSs unless
they have a reason to know that it is inaccurate
Carcinogenicity
Appendix A.6
 For carcinogens
 OSHA is allowing classifiers to use determinations of
Internal Agency for Research on Cancer (IARC) and
National Toxicology Program (NTP) for classification
or to perform their own hazard evaluation
 New Appendix F (Non-mandatory)
» Guidance for Hazard Classifications
Regarding Carcinogenicity
Appendix B – Physical Criteria
 The physical hazard criteria in Appendix B—
Physical Criteria (Mandatory) are based on the
United Nation (UN) Recommendations for the
Transport of Dangerous Goods, and are
already used by the Department of
Transportation (DOT) in hazardous materials
regulations
 OSHA has adopted the GHS criteria for all
physical hazards
Written Program
1910.1200(e)(1) & (4)
 Employer must have a written hazard
communication program
 It must be available upon request to:
 Employees and/or their designated
representative
 OSHA
Written Program
1910.1200(e)
 Must contain how the following will be met:
 Labels and other forms
of warning
 Safety data sheets
 Information and training
 List of chemicals
Written Program
1910.1200(e)(1)(ii)
 Must also contain:
 Methods used to inform employees of the hazards
associated with non-routine tasks
» Example: cleaning a reactor vessel
 Hazards associated with chemicals contained in
unlabeled pipes in the workplace
Written Program
1910.1200(e)(2)
 Multi-employer workplaces
 Methods used to inform other employer(s):
» SDS access
» Precautionary measures during normal operating
conditions and in foreseeable emergencies
» Labeling system (in-house or workplace labeling)
Written Program
1910.1200(e)(5)
 When employees travel between workplaces
during a work shift (their work is carried out at
more than one geographical location)
 HazCom program may be kept at a primary
workplace facility
Labeling
1910.1200(c)
 “Label” - An appropriate group of written,
printed or graphic information elements
concerning a hazardous chemical that is
affixed to, printed on, or attached to the
immediate container of a hazardous chemical,
or to the outside packaging
Labeling
 Must be in English and prominently
displayed:
 Product identifier
 Signal word
 Hazard statements
 Pictogram(s)
 Precautionary statement(s)
 Name, address and telephone number of
manufacturer/importer/responsible party
1910.1200(f)
Harmonized Information
 Signal words, pictograms and hazard
statements have been harmonized and
assigned to each hazard class and category in
the GHS
 Once a chemical has been classified, the label
preparer can obtain the relevant harmonized
information from Appendix C—Allocation of
Label Elements (Mandatory)
Harmonized Information
Danger vs Warning
 “Signal word” - A word used to indicate the
relative level of severity of hazard and alert the
reader to a potential hazard on the label
 “Danger” is used for the more severe hazards
 “Warning” is used for the less severe
Hazard Statements
 “Hazard statement” - A statement assigned to
a hazard class and category that describes the
nature of the hazard(s) of a chemical,
including, where appropriate, the degree of
hazard
 Example: Harmful if inhaled (for Category 4 Acute
Toxicity - Inhalation)
Pictogram
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Signal word
Hazard statement
Danger
Fatal if inhaled
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Danger
Fatal if inhaled
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Danger
Toxic if inhaled
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Warning
Harmful if inhaled
Pictograms
 “Pictogram” means a composition that may
include a symbol plus other graphic elements,
such as a border, background pattern or color,
that is intended to convey specific information
about the hazards of a chemical
 Eight pictograms are designated under this
standard for application to a hazard category
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Pictograms
 Red borders required
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 No blank pictograms
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Precautionary Statements
 “Precautionary statement” means a phrase that
describes recommended measures that should be
taken to minimize or prevent adverse effects
resulting from exposure to a hazardous chemical,
or improper storage or handling
 Example for Explosives, Division 1.1, 1.2 and 1.3
» Keep away from heat/sparks/open flames/hot surfaces. No
smoking
» Keep wetted with…
» Ground/bond container and receiving equipment
» Do not subject to grinding/shock/…/friction
» Wear face protection
Precautionary Statements
 OSHA has adopted the precautionary
statements from the GHS
 Statements are in Appendix C—Allocation of Label
Elements, and assigned to classes and categories
 Also provides better consistency and
comprehensibility than allowing the development of
company-specific statements
 Rule provides flexibility for precautionary and
hazard statement application
Additional Requirements
 Harmonized information is to be provided
together on the label
 Signal words, pictograms and hazard statements
 All information is to be prominently displayed
and in English (although other languages may
also be provided)
 Requirement that information not conflict with
transport labels remains the same
Example of Appendix C Label Elements
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Updating Labels
 HCS 1994 required labels to be updated within
three months but a stay prevented OSHA from
enforcing this requirement
 This rulemaking removes the stay - Labels are
to be updated within six months of getting
new and significant information about the
hazards or ways to protect those exposed
Label Example
Labeling
1910.1200(f)
 Solid materials
 Solid metal, wood or plastic items not exempted as
articles due to downstream use
» Label must be transmitted to customer with initial shipment
» Does not apply to any chemicals used with or present with
materials to which employees may be exposed by handling
• Examples: cutting fluids, pesticides
Labeling
1910.1200(f)(6)
 Workplace labeling
 Each hazardous chemical container must be
labeled, tagged or marked with either
» Information required for labels on shipped containers
Or
» Product identifier and words, pictures, symbols, or
combination thereof, which provide at least general
information regarding the hazards of the chemicals
(In conjunction with the other information immediately available to employees
under the hazard communication program)
Labeling
1910.1200(f)(8)
 Labeling exemption
 Portable containers that are
intended for immediate use
by the employee who performs
the transfer of hazardous
chemical from a labeled
container
 Immediate use
» Under the control of, and
» Used only by the employee, and
» Within the work shift of transfer
Unlabeled and
Uncontrolled Portable
Container
Safety Data Sheets
1910.1200(g)
 “Safety Data Sheet (SDS)”
 Written or printed material concerning a hazardous
chemical that is prepared in accordance with
paragraph (g)—Safety Data Sheets
Safety Data Sheets
 Chemical manufacturers and
importers must obtain or
develop an SDS
 Employers must have an
SDS in the workplace for
each chemical they use
 Must be in English
1910.1200(g)
Safety Data Sheets
1910.1200(g)
 16-section safety data sheet
 Several sections are not mandatory since they
address information outside OSHA’s
jurisdiction (Sections 12-15)
 Appendix D—Safety Data Sheets (Mandatory)
provides the details of what is to be included in
each section
 No subheading in Sections 1-11 and 16 can be
left blank
Safety Data Sheet Format
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
1910.1200(g)
Identification of the substance or mixture and of the supplier
Hazards identification
Composition/information on ingredients
First-aid measures
Fire-fighting measures
Accidental release measures
Handling and storage
Exposure controls/personal protection
Physical and chemical properties
Stability and reactivity
Toxicological information
Ecological information (non-mandatory)
Disposal considerations (non-mandatory)
Transport information (non-mandatory)
Regulatory information (non-mandatory)
Other information, including date of preparation or last revision
Safety Data Sheets
1910.1200(g)
 Chemical manufacturers or importers must
ensure that distributors and employers are
provided an appropriate SDS
 With their initial shipment, and
 With the first shipment after an SDS is updated
Safety Data Sheets
1910.1200(g)
 SDS access for employees
 Readily accessible
 During work shift
 Electronic and other alternatives are acceptable
 No barriers to immediate employee access
 When employees travel between workplaces
during a work shift
 May be kept at primary workplace
Employee Exposure Records
1910.1200(g)(11)
 References 1910.1020—Access to Employee
Exposure and Medical Records
 An “employee exposure record” includes Material
Safety Data Sheets (MSDS)*
 In the absence of an MSDS, a chemical inventory
 Must be held and maintained at least 30 years
 Employee access to record
* The 3/26/2012 final rule did not include a revision to 1910.1020
Information and Training
1910.1200(h)
 Training provided to employees upon:
 Initial employment
 When new hazards are introduced into the workplace
 Information
 Requirements of this section
 Operations in their work area where hazardous chemicals are
present
 Location and availability:
• Written hazard communication program
• List(s) of hazardous chemicals
• Safety data sheets
Information and Training
1910.1200(h)
 Training
 Methods and observations to detect presence
or release of chemicals
 Physical, health, simple asphyxiation, combustible dust and
pyrophoric gas hazards
 Hazards not otherwise classified
 Measures to protect themselves
 Details of the hazard communication program:
» An explanation of the labeling system
» Safety data sheets
» How employees can obtain/use the appropriate hazard information
Trade Secrets
1910.1200(i)
 Under the N.C. Right to Know Act (NCGS 95-
173, Article 18), hazard information on chemicals
deemed as a trade secret are to be provided to
the local fire chief, who must hold the information
in confidence
 Chemical manufacturers, importers or employers
may withhold specific information from the SDS
 They must be able to support that the information
withheld is a trade secret
Trade Secrets
1910.1200(i)(2)
 Emergencies
 Where a treating physician or nurse determines that
a medical emergency exists, the chemical identity
and/or specific percentage of the composition of the
trade secret must be disclosed
Trade Secrets
1910.1200(i)(3)
 Non-emergencies
 Disclose to health professional if:
» Requested in writing; and
» Describes one or more occupational health need
• Used to assess an employee’s exposure
• Provide medical treatment
• Design engineering controls
• Assessing hazards
• Conducting medical surveillance
• Assessing personal protective equipment
• Conducting medical studies
Effective Dates
1910.1200(j)
Effective Completion Date
Requirement(s)
Who
December 1, 2013
Train employees on the new label
elements and safety data sheet
(SDS) format.
Employers
June 1, 2015*
Compliance with all modified
provisions of this final rule, except:
Chemical manufacturers,
importers, distributors and
employers
December 1, 2015
The Distributor shall not ship
containers labeled by the chemical
manufacturer or importer unless it is
a GHS label.
June 1, 2016
Update alternative workplace
labeling and hazard communication
program as necessary, and provide
additional employee training for
newly identified physical or health
hazards.
Employers
Transition Period to the effective completion
dates noted above.
May comply with either 29 CFR
1910.1200 (the final standard), or
the current standard, or both.
Chemical manufacturers,
importers, distributors, and
employers
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During the transition period after the final rule is promulgated, either the HCS 1994 or the new final rule (HCS 2012)
can be followed
Changes Affecting the Workplace
 Employers
 Training on label elements - pictograms, signal
words, hazard statements and precautionary
statements
 Training on new SDS format
 Continue to maintain the updated SDSs
 Manufacturers
 Initial start-up costs associated with reclassification,
producing new labels, safety data sheets and
training
Other Affected Standards
 Many other OSHA standards contain criteria
related to defining hazards, as well as other
provisions, that rely on those criteria
 OSHA undertook a comprehensive review of its
rules to identify what needed to be changed
 OSHA maintained the scope of existing standards
Other Affected Standards
 Standards affected ranged from comprehensive
rules, such as that addressing flammable liquids,
to the label and sign provisions of substancespecific health standards
 In the rulemaking, OSHA modified all standards
that needed to be consistent with HCS 2012
 Included all the substance-specific standards as well as
many safety standards that involve physical hazards
Examples of Harmonized
Changes to Other Standards
Affected by the GHS Revision
Flammable Liquids – 29 CFR 1910.106
 HCS 1994
− Paragraph (b)(2)(iv)(g) - Flame arresters or venting devices
required in paragraph (f) may be omitted for Class IB and IC
liquids where conditions are such that their use may, in case of
obstruction, result in tank damage
 HCS 2012
− Paragraph (b)(2(iv)(g) - Flame arresters or venting devices
required in paragraph (b)(2)(iv)(f) of this section may be
omitted for Category 2 flammable liquids and Category 3
flammable liquids with a flashpoint below 100 F (37.8 C)
where conditions are such that their use may, in case of
obstruction, result in tank damage
Note: In 1926.152, same changes to paragraph (i)(2)(iv)(F) and (i)(2)(iv)(G).
PSM – 29 CFR 1910.119(a)(1)(ii)
 HCS 1994
− A process which involves a flammable liquid or gas (as defined
in 1910.1200(c) of this part) on site in one location, in a
quantity of 10,000 pounds (4,535.9 kg)
 HCS 2012
− A process which involves a Category 1 flammable gas (as
defined in 1910.1200 (c)) or a flammable liquid with a
flashpoint below 100 F (37.8 C) on site in one location, in a
quantity of 10,000 pounds (4,535.9 kg)
Updated Websites
GHS Webpage:
http://www.osha.gov/dsg/HazCom/index.html
Hazard Communication Webpage:
http://www.osha.gov/dsg/HazCom/index2.html
NCLABOR Webpage:
http://www.nclabor.com/osha/etta/A_to_Z_Topics/a_to_z_toc.htm
Thank You For Attending!
Final Questions?